Privacy Policy — How escala88 Handles Your Data

This Privacy Policy applies to all personal information collected, processed, stored, and used by escala88 ("escala88," "we," "us," "our") in connection with the operation of the escala88 online gaming platform accessible at escala88.com, including any associated account management interfaces accessible via mobile browser.

escala88 acts as the data controller with respect to the personal information of registered players, prospective users, and visitors to the platform. As data controller, escala88 determines the purposes and means by which personal data is processed and is responsible for ensuring that such processing is conducted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, together with any applicable directions or guidelines issued by PAGCOR in relation to player data handling.

This policy applies to all data subjects who interact with the escala88 platform, including registered account holders, individuals in the process of registration, and anonymous visitors who interact with the platform's publicly accessible features. It covers personal data collected through the platform itself, through the account registration and KYC process, through payment processing, through customer support interactions, and through automated data collection mechanisms such as cookies and server logs.

escala88 collects the following categories of personal data from users of the platform:

escala88 does not knowingly collect sensitive personal information beyond what is strictly required for identity verification and compliance with anti-money laundering (AML) obligations. Where sensitive data is collected — such as a copy of a government-issued ID — it is handled with heightened security measures and accessed only by authorized personnel on a strict need-to-know basis.

escala88 collects personal data through the following means:

• Direct submission — information you provide when registering an account, completing KYC verification, submitting deposit or withdrawal requests, contacting customer support, or updating your account profile.
• Automated technical collection — data gathered automatically when you visit the escala88 platform, including IP addresses, browser metadata, device identifiers, and session data collected via server logs and cookies (see Section 7).
• Payment processor data — transaction reference data relayed to escala88 from GCash, PayMaya, and partner banking institutions upon execution of a deposit or withdrawal. escala88 does not directly capture or store your full GCash or bank login credentials.
• Third-party identity verification providers — where escala88 uses a third-party KYC or liveness verification service to assist in confirming the authenticity of identity documents, data obtained through that process is shared between escala88 and the provider solely for verification purposes.
• Game provider data feeds — game studios and live dealer providers may transmit game session metadata to escala88 to enable accurate wallet crediting, bonus tracking, and dispute resolution.

escala88 uses the personal data it collects for the following purposes:

1. Account creation and management — to register, verify, and maintain your escala88 player account and authenticate your identity at login.
2. KYC and age verification — to confirm that you are at least 21 years of age and meet the eligibility requirements applicable to escala88 under PAGCOR's framework. Age verification is a mandatory legal obligation and cannot be waived.
3. Payment processing — to process deposits from and withdrawals to your nominated payment methods, including GCash, PayMaya, BPI, BDO, and Metrobank.
4. Anti-money laundering compliance — to conduct transaction monitoring, source-of-funds assessments, and reporting obligations as required under the Philippine Anti-Money Laundering Act (AMLA) and related regulations.
5. Platform operation and improvement — to deliver the escala88 gaming experience, resolve technical issues, analyze usage patterns, and improve platform performance and game offerings.
6. Fraud and security — to detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other prohibited conduct as defined in the Terms and Conditions.
7. Customer support — to respond to your queries, process complaints, and manage support cases effectively and promptly.
8. Responsible gaming — to administer self-exclusion orders, deposit limits, session controls, and other responsible gaming tools you have activated, and to identify indicators of problem gambling where required by regulation.
9. Regulatory compliance and reporting — to respond to lawful demands from PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), or other competent Philippine government authorities.
10. Marketing communications — to send you information about relevant escala88 promotions, bonuses, and new features, where you have provided consent to receive such communications. You may withdraw marketing consent at any time through your account settings.

Under the Philippine Data Privacy Act of 2012 (RA 10173), escala88 relies on the following lawful bases for processing your personal data:

• Contractual necessity — processing is necessary to perform the contract between you and escala88 (i.e., the player agreement established at registration). This covers account management, deposit and withdrawal processing, game delivery, and customer support.
• Legal obligation — processing is required to comply with mandatory legal and regulatory requirements applicable to escala88 as a PAGCOR-regulated operator, including KYC obligations, AML reporting under AMLA, and age verification requirements.
• Legitimate interests — processing is necessary for escala88's legitimate interests in operating a secure, fraud-free, and financially sound platform, provided those interests are not overridden by your fundamental rights. This basis covers security monitoring, fraud detection, and responsible gaming analytics.
• Consent — for processing activities that are not strictly necessary for the provision of the service — particularly direct marketing communications — escala88 relies on your freely given, informed, and specific consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

escala88 does not sell, rent, or trade your personal information to any third party for their independent commercial purposes. Data is shared only in the following circumstances and with the following categories of recipients:

• Payment service providers — GCash (GXI / Globe Fintech), PayMaya (Voyager Innovations / Maya Bank), and partner banks (BPI, BDO, Metrobank) receive the minimum transaction data necessary to process deposits and withdrawals.
• KYC and identity verification providers — third-party services engaged by escala88 to assist with document authentication and liveness checks during the KYC process, acting under escala88's instructions as data processors.
• Game providers and software licensors — Pragmatic Play, PG Soft, Jili, and other studios receive account and session identifiers necessary to deliver games, maintain game session integrity, and process winnings. These providers are contractually prohibited from using escala88 player data for their own independent purposes.
• Regulatory and law enforcement authorities — PAGCOR, the National Privacy Commission, the AMLC, the Bureau of Internal Revenue (BIR), and other competent government bodies, where escala88 is legally required to disclose data.
• Fraud prevention and security services — third-party security and fraud detection tools used to protect the escala88 platform and its players, operating as data processors under escala88's direction.
• Professional advisors — legal, accounting, and compliance advisors engaged by escala88 who are bound by professional confidentiality obligations.

All third parties with whom escala88 shares personal data are required by contract to implement appropriate data security measures and to process personal data only as instructed by escala88 and in compliance with applicable law.

escala88 uses cookies and similar tracking technologies to enable the operation of the platform, improve user experience, and conduct analytics. A cookie is a small text file placed on your device by a website you visit. Cookies do not contain executable code and cannot carry viruses.

escala88 uses the following categories of cookies:

• Strictly necessary cookies — essential to the functioning of the platform. These include session authentication cookies that keep you logged in to your escala88 account during a session. These cannot be disabled without severely impairing platform functionality.
• Functional cookies — used to remember your preferences such as preferred language, remembered login credentials (if "Remember Me" is enabled), and display settings. Disabling these cookies will affect the personalized experience of the platform.
• Analytics cookies — used to collect aggregated, anonymized data about how users interact with the escala88 platform, including pages visited, session duration, and error rates. This data is used to improve the platform and does not identify individual users.
• Security cookies — used to detect and prevent fraudulent activity, including CSRF protection tokens and session integrity checks.

You may manage cookie preferences through your browser settings. Note that disabling cookies categorized as "strictly necessary" will prevent you from logging in to your escala88 account. escala88 does not use third-party advertising cookies or cross-site behavioral tracking technologies.

escala88 retains personal data only for as long as it is necessary for the purposes for which it was collected, or as required by applicable law and regulation. The following retention principles apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data must be retained beyond the standard period due to an ongoing legal dispute, regulatory investigation, or court order, it will be retained only for the duration necessary to resolve that matter.

escala88 implements technical and organizational security measures commensurate with the nature and sensitivity of the personal data it holds. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your browser and the escala88 platform is encrypted using TLS 1.2 or higher (256-bit SSL). This prevents interception of login credentials, financial data, and other sensitive information during transmission.
• Encryption at rest: Sensitive stored data, including KYC documents and financial identifiers, is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Strict role-based access controls limit access to personal data to escala88 personnel who require it to perform their specific duties. Access logs are maintained and reviewed regularly.
• OTP authentication: Sensitive account actions — including login from an unrecognized device and password resets — require one-time password (OTP) verification via your registered Philippine mobile number.
• Intrusion detection: The escala88 platform is monitored continuously for unauthorized access attempts, unusual traffic patterns, and security anomalies.
• Third-party security assessments: escala88's security architecture is subject to periodic review to identify and remediate vulnerabilities.

While escala88 takes all reasonable precautions to protect your personal data, no internet-based system can guarantee absolute security. You play an important role in maintaining the security of your own account by keeping your credentials confidential and using the account security features available to you. In the event of a data breach that is likely to adversely affect your rights and freedoms, escala88 will notify the National Privacy Commission and affected data subjects in accordance with the Philippine Data Privacy Act's breach notification requirements.

As a data subject under the Philippine Data Privacy Act (RA 10173), you hold the following rights with respect to your personal data held by escala88. These rights may be exercised at any time by contacting the escala88 Data Privacy Officer through the channels set out in Section 14.

escala88 will respond to data subject rights requests within thirty (30) days of receipt. Where a request is complex or requires additional time, we will notify you of the extended timeframe and the reason for it within the initial thirty-day period. Requests are processed free of charge; where requests are manifestly unfounded or excessive, a reasonable administrative fee may apply.

escala88 does not knowingly collect or process personal data from individuals who are under 21 years of age. Age is verified as part of the mandatory KYC process prior to activation of full account privileges. Where escala88 discovers that personal data has been collected from a minor, that data will be deleted promptly and the account will be permanently closed.

If you are a parent or guardian and believe that a person under 21 may have registered or used the escala88 platform, please contact us immediately via live chat or at the email address in Section 14. We will investigate and take appropriate action, including account closure and data deletion, without undue delay.

The escala88 platform may contain references to third-party services — such as payment processors (GCash, PayMaya) and game providers — that operate under their own privacy policies. Once you navigate to or interact with a third-party service, escala88's Privacy Policy no longer applies and escala88 accepts no responsibility for the privacy practices of those third parties.

escala88 encourages you to review the privacy policies of any third-party service you interact with in connection with the use of the platform, particularly your payment provider (GCash, PayMaya, or your bank) whose own data handling practices govern the information you provide directly to them during payment authorization.

escala88 reserves the right to update or amend this Privacy Policy at any time. Material changes — particularly those that affect the purposes for which data is processed, the categories of data collected, or the rights available to you — will be communicated to registered players via a platform notification, via in-account messaging, or via your registered mobile number or email address prior to the changes taking effect.

The "Last Updated" date at the top of this document reflects the date of the most recent amendment. We recommend that all escala88 players review this Privacy Policy periodically. Your continued use of the platform following any posted amendment constitutes your acknowledgment of the updated policy. If you disagree with any material change, you should cease using the platform and may request account closure in accordance with the Terms and Conditions.

For any questions, concerns, or requests related to this Privacy Policy or to the personal data escala88 holds about you — including the exercise of any data subject rights under Section 10 — please contact us through the following channels:

• Live Chat: Available 24/7 directly on the escala88 platform at escala88.com — the fastest route to our team for urgent privacy concerns.
• Email (Data Privacy inquiries): [email protected] — include "Data Privacy Request" in the subject line to ensure your inquiry is routed to the appropriate team.

All privacy-related inquiries are handled by designated personnel trained in Philippine Data Privacy Act compliance. You have the right to escalate unresolved privacy complaints to the National Privacy Commission of the Philippines (NPC) if escala88's response is unsatisfactory.